IPC Safety Audit
IPC Safety Audit
IPC Safety Audit
ASSOCIATION CONNECTING
ELECTRONICS INDUSTRIES
ASSOCIATION CONNECTING
ELECTRONICS INDUSTRIES
The
IPC's
EHS
Committee;
John
Sharp,
ASSOCIATION CONNECTING
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PURPOSE
Establish a safety and health audit checklist for printed circuit board manufacturing facilities
that will help facilities manage their safety and health obligations.
SCOPE
This audit checklist is designed to cover a facilitys compliance with major OSHA requirements and a facilitys compliance with more general, routine requirements. Although this
checklist will facilitate compliance with Occupational Safety and Health Administration
(OSHA) rules and regulations, the checklist is merely a guide and should not be used to
guarantee legal compliance.
METHODOLOGY
OSHA requirements are triggered by specific workplace factors the presence of certain
machinery, chemicals and workplace exposures, as well as more general requirements
that apply to most workplaces. It is recommended that auditors perform two difference
inspections to capture these varying types of requirements. The first inspection checklist
is geared toward assessing compliance with major OSHA requirements; the second
checklist is geared toward assessing compliance with more general OSHA requirements.
According to California OSHA, the following violations are typical at PWB facilities:
Miscellaneous electrical violations
Lack of written plans
Absence of personal protective equipment
Lack of inoperative or distant eye wash/deluge shower
Violations involving fork lifts and bench grinders
Noise exposures to routers and drills
Tank safety/labeling
Lack of monitoring for lead exposures near soldering operations
Unguarded shafts, chain drives and belts
Failure to check ventilation systems
This audit program is designed to capture typical PWB violations and help members
eliminate their occurrence or address them as soon as possible once they are identified.
STEP #1 Determine Compliance Status
Walk-through facility and determine whether facility has achieved compliance with more
general OSHA requirements (please see Facility Walk Through Audit on page 16).
STEP #3 Correct all Potential Violations Identified
The main benefit of an audit program is to identify potential violations so that facilities can
correct them before they result in OSHA fines or penalties. Most importantly, however, timely
correction will prevent injury to employees and ensure a productive and safe workplace.
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Step #1
This matrix outlines major OSHA requirements, which may apply to particular PWB facilities. If there is an A in the Applicability column, the requirement applies to all PWB
facilities. If there is an S in this column, the requirement applies to some PWB facilities
and facilities should reference the relevant regulatory summary sheet to determine whether
the requirement is triggered.
Once it is determined which standards are triggered, facilities should reference the summary
sheets to determine whether they appear compliant. If key regulatory elements are in place
and appear sufficient, check the box labeled Compliant. Please note, however, the appearance of compliance does not guarantee compliance.
Please note:
These standards are ranked according to their frequency of occurrence for the PWB industry.
Although not all major OSHA requirements are listed, the most common standards applicable to the industry are included. Others, however, may be triggered in certain circumstances.
Standard
Applicability
Plan
Training
Records
Other
Compliant
Hazard
Communication
Chemical Specific
Programs
Hazard Assessment
Lockout/Tagout
Respiratory
Protection
Illness/Injury
Records
Fork Truck
Standard
Bloodborne
Pathogens
Hearing
Conservation
Hazardous Waste/
Emergency Response
Employee Exposure
Records
Permit-Required
Confined Space
Emergency
Action Plan
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Purpose
Standard applies to any chemical known to be present in the workplace in manner that may
result in employee exposure under normal conditions of use or foreseeable emergency.
Covered PWB chemicals include sulfuric acid, sodium hydroxide, screening dyes, ammonia,
chlorine, lead, and formaldehyde.
COMPLIANCE CHECKLIST:
Written Program
Does facility have written program, outlining procedures facility uses to communicate
chemical hazards to employees? Plan must cover labeling, compilation of material safety
data sheets (MSDSs), and employee training.
Does plan include current inventory list of all hazardous chemicals used in the workplace?
Check list against available MSDSs. Do chemical names match MSDS names?
Training
Does facility ensure that employees are trained on hazardous substances in their work
area (i.e., how to read an MSDS and understand hazcom labels) and where to obtain hazcom
information at the time of their initial assignment and whenever a new chemical is introduced into their work area?
Does employer maintain employee training records for a period of not less than three
years after workers employment has been terminated? Records must provide the date/
description of instruction given and the name/job description of the employee, including
date of hire and/or transfer.
Does employer have file containing MSDSs for each chemical present in the workplace
or that enters the plant either purchased or as sample? If a listed substance has no MSDS,
contact manufacturer or supplier. Employer must make MSDSs readily available to employees,
shift supervisors, and safety and emergency personnel in their work areas during all operating
shifts. According to OSHA, electronic versions of MSDSs are acceptable if readily accessible.
Labeling
Are all chemicals present in the workplace properly labeled with the identity and hazard
warning of the chemical? Inspector should determine whether label name matches name
on MSDS. Dip tanks containing sulfuric acid, sodium hydroxide, and other hazardous
substances must be labeled and include hazard warning. Employers must ensure that when
chemicals are transferred from labeled containers, labeling requirements are met. When
chemicals are transferred into portable containers for immediate use (i.e., by one person
during their shift when under their exclusive control), hazcom labeling is not required.
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Process steps that may trigger program include HASL, wave soldering, and routing for lead;
electroless copper for formaldehyde. Rule is triggered when air monitoring shows that employee
exposures may exceed chemicals action level (30 ug/m3 for lead, 0.5 ppm for formaldehyde
both averaged over 8-hour period) or short-term exposure level (2 ppm over 15 minute period)
for formaldehyde.
COMPLIANCE CHECKLIST:
Written Program
If monitoring shows that worker exposures may exceed the PEL (50 ug/m3 for lead, 0.75 ppm
for formaldehyde both averaged over an 8-hour period) or short-term exposure limit (STEL) for
formaldehyde (2 ppm measured over 15 minutes), does facility have written compliance program,
describing each operation where exposures may be exceeded/how exposures will be reduced?
Training
If lead is used in facility, has general awareness training been provided to all employees?
If monitoring suggests that some employees may be exposed to lead or formaldehyde above
their action levels, has employer trained all potentially affected employees annually?
Testing/Monitoring/Medical Surveillance
Has facility conducted initial surveillance of potential exposure areas and obtained time-weighted
averages representing potential worker exposures? Measurements should be repeated if there is
any change in production, process, or control that might result in increased employee exposure.
Has facility maintained records of surveillance results?
If surveillance shows potential exposures meet or exceed action levels for formaldehyde or
lead (0.5 ppm for formaldehyde, 30 ug/m3 for lead) or STEL for formaldehyde (2 ppm over
15 min.), has facility conducted monitoring and informed employees of results in writing?
Has facility maintained monitoring results?
If monitoring shows that exposure levels meet or exceed the action level or STEL for formaldehyde, has facility conducted periodic monitoring at regular intervals (check regulation)? Has
facility maintained records of periodic surveillance tests?
If ventilation is used to control exposure, have measurements been taken, demonstrating its
effectiveness? Measurements should be made quarterly and within 5 days of a production
change that may result in exposure. Has facility maintained testing records?
Has facility instituted medical surveillance program for employees who may be exposed to
chemicals above their action levels or STEL for formaldehyde and made medical surveillance
records available to employees and their representatives?
Other
Has facility instituted practices to reduce potential chemical exposure (i.e., instituting good
housekeeping practices?
If exposure may exceed PEL or STEL, has facility posted signs indicating potential exposure?
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Outline general requirements for eye, hand, and foot protection. Workplace hazard assessments help identify need for personal protective equipment (PPE) for each PWB process.
Applicability: Every PWB process potentially involves eye, head, and foot hazards. OSHA
requires the use of PPE to reduce employees exposures. Latex gloves are not recognized
as proper PPE for chemical protection.
COMPLIANCE CHECKLIST:
Written Plan
Has facility prepared workplace hazard assessment/certification for each process that
presents eye, hand, or foot hazard? Assessment should assess potential for eye, face, head,
feet, hand, and body damage from the following hazards: impact, penetration, compression,
chemical, heat/cold, light radiation, harmful dust, and electrical shock, noise, or other.
Training
Has facility trained each employee that is required to use PPE based upon facility-specific
hazard assessments? Training must cover reasons for PPE and its proper use, inspection, care
and storage. Refresher training is required if employer has reasons to believe that employee
lacks PPE knowledge, such as when changes in workplace render PPE obsolete.
Has facility certified at least annually that each affected employee has received and
understood PPE training? Inspect training records.
Recordkeeping
Has facility certified in writing, at least annually, that hazard assessments have been
completed?
Inspection/Maintenance
After hazard assessments are completed, PPE has been assigned, and employees have
been trained, employers must verify that employees are following proper PPE procedures.
This can be done during audit by questioning employees that they understand PPE use,
care, and storage.
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Lockout/Tagout Program
Purpose
Applies to all PWB facilities. Standard applies to most servicing and/or maintenance
activities which take place during normal production operations if employee is required
to remove/bypass a guard or other safety device or an employee is required to place any
part of his/her body into an area on a machine or piece of equipment where work is actually
performed. Compliance is not required for minor tool changes, adjustment , and other minor
servicing activities if they are routine, repetitive, and integral to the equipments use
provided that the work is performed using alternative methods of protection.
COMPLIANCE CHECKLIST:
Written Program
If any machines are covered by standard, does facility have a written program? Program
must address employee training, periodic inspections, servicing or maintenance procedures,
start-up and re-energizing procedures, and procedures for lockout/tagout of equipment.
Does program contain specific procedural steps for shutting down, isolating, blocking,
and securing each covered machine/equipment to control hazardous energy (i.e., separate
procedure for each machine)?
Training
Has facility provided initial training to all employees that work in manufacturing area on
lockout/tagout program? Employers must train affected employees (i.e., ones that work in
area where LO/TO will occur) and authorized employees (i.e., ones that will conduct
LO/TO) on lockout/tagout procedures at their initial employment and whenever there is
a change in equipment, job assignment, or when employer has knowledge that refresher
training is necessary. Check training records.
Recordkeeping.
Does facility maintain certification records showing compliance with training requirements? Employer must certify that employee training has been accomplished and is being
kept up to date. Certification must contain each employees name and date of training.
Check records.
Does facility maintain certification records showing compliance with inspection requirements? Certification must identify machine or equipment on which the energy control
procedure was being utilized, the date of the inspection, the employees included in the
inspection, and the person who performed the inspection. Check records.
Inspection
Does facility conduct inspections (at least annually) to ensure that major elements of
program (i.e., employee training, written procedures, periodic inspection and hardware
requirements) are being followed? Check inspection records.
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Purpose
Protect employees that operate in workplaces that exceed the Permissible Exposure Limit
for air pollutants.
Applicability
Requirements depend upon Permissible Exposure Limit (PEL) results for processes. If exposure from process exceeds PEL, requirements are triggered. Most common PWB operations
that trigger requirements include etcher cleaning, pollution control, and emergencyresponse.
The following chemicals can generate toxic vapors during handling: formaldehyde, ammonia
in alkaline etchant, hydrochloric acid, chlorine in cupric chloride, glycol ethers, and acid mists.
COMPLIANCE CHECKLIST:
Written Program
Has facility established written program that accounts for the different airborne hazards
within its workplace? Program should govern the selection and use of respirators in these areas.
Does program contain detailed maintenance procedures for cleaning and disinfecting,
drying, storage, and inspection of respirators?
Does program contain written procedures for training employees, providing pulmonary
function and fit tests to affected employees, and maintaining workplace and medical
surveillance records?
Training
Have employees that will use respirators been trained on the proper use, care, storage,
and inspection of respirators at least annually? Check training records.
Recordkeeping:
Have employers evaluated the workplace and certified that the written program is implemented properly and that employees are using their respirators properly? Evaluation must
be conducted as often as necessary to maintain the programs effectiveness.
Testing/Inspection
Has facility provided employees that will use respirators with fit tests and pulmonary
function tests (if necessary) and conducted medical surveillance of such employees to
determine whether exposure to harmful levels of airborne contaminants may have occurred?
Check testing and surveillance records.
Are all respirators inspected routinely before (i.e., have positive and negative tests
been conducted) and after each use (i.e., are they cleaned and disinfected)? Check
inspection records.
Have all self-contained breathing equipment been inspected monthly? Respirator inspection
must include a check of the tightness of connections and condition of the facepiece, headbands, valves, connecting tube, and cannister (there must be at least 90% air in cannister).
A record should be kept of inspection dates and findings for respirators maintained for
emergency use.
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Purpose
COMPLIANCE CHECKLIST:
Recordkeeping
Does facility keep workplace injury and illness records on OSHA 200 log as required by
OSHA? Each page must be complete and include facility name, address and injury/illness
totals at bottom of page.
Does facility supplement OSHA 200 logs with supplementary record of recordable
occupational injuries and illnesses (OSHA Form 101)? Accident and investigation forms
(OSHA 101 Logs) must contain at least the same information as OSHA 200 Logs and
must be available in the facility without delay and at reasonable times for examination.
They must be maintained for at least five years.
Posting
Did facility post annual summary of workplace injuries and illnesses from February 1
to March 1 each year?
Is OSHA poster prominently displayed in facility where all employees can see it?
Other
Does facility have a return-to-work program? This is not a federal requirement; however,
the implementation of such a program constitutes good business practice because it helps
facilities reduce their workers compensation costs.
Note: OSHA requires facilities to contact federal OSHA within 8 hours when there is a
fatality or when 3 or more employees are hospitalized.
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Purpose
If fork trucks are used on-site (e.g., shipping, receiving, and warehouse areas), program
is required. Standard may also apply to powered walking units and electric motorized
pallet jacks.
COMPLIANCE CHECKLIST:
Training
Are only licensed operators allowed to operate fork trucks? Refresher training should
occur very three years unless employer has knowledge that refresher training is necessary.
New standard requires classroom training and on-truck training. Check for training records.
Inspection/Maintenance
Have fork trucks been inspected before each shift? It is recommended that employers
have manufacturers inspect fork trucks periodically. Check for inspection records.
Are fork trucks regularly maintained? Maintenance must occur by authorized individual
such as manufacturers representative. A copy of the maintenance report should be kept
on file. Check for maintenance records.
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Purpose
Applies to all PWB facilities. Standard is required whenever there is potential contact
with blood or unknown body fluids. Standard covers first aid responders and custodians.
COMPLIANCE CHECKLIST:
Written Plan
Does facility have written exposure control plan consisting of a list of employees whose
job potentially exposes them to bloodborne diseases, a list of all tasks that present exposure
potential, and a procedure for evaluating exposure potential?
Training
10
If any contact with blood or infectious material is possible, does facility provide PPE?
Employer is responsible for the maintenance and repair of all PPE.
If employee is exposed to blood or infectious material, has facility implemented postexposure follow-up?
Does facility ensure that any items that may become contaminated with bodily fluids
are properly disposed of in biohazard disposal bags, which can be obtained from a safety
supply company?
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Purpose
COMPLIANCE CHECKLIST:
Written Plan
Does facility have written hearing conservation program that covers the following
elements: employee monitoring, audiograms, surveillance, training, and the provision
of hearing protection devices?
Training
Does facility provide basic training on how ear works and the use and importance
of hearing protection on an annual basis? Check training records.
Testing/Monitoring
Does facility implement a monitoring system in areas where employee exposure may
equal or exceed relevant decibel level depending upon work shift? Monitoring must be
repeated whenever there is a change in the production process, equipment, or controls
that increases noise exposure. Check monitoring records.
Other
Does employer provide ear protection options to workers (i.e., ear plugs and alternative)?
Does facility post notice indicating that standard is triggered and ear protection is
required in affected areas of facility?
11
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Provide means to identify, evaluate, and control safety and health hazards, and provide a
program for emergency response in hazardous waste operations.
Applicability
All facilities must have HAZWOPR plan; however, extent of plan depends upon level of
response chosen by facility. Facility can choose to respond in a minimal way (i.e., call fire
department) or respond in a more involved way (i.e., emergency responders with selfcontained breathing apparatus). Program applies when a chemical spill occurs and employees
are designated to respond from other areas of facility.
COMPLIANCE CHECKLIST:
Written Plan
Has facility developed and implemented a written program for employees involved in
hazardous waste operations, such as wastewater treatment?
Does program identify, evaluate, and control safety and health hazards and provide for
emergency response? Program must also cover employee training, medical surveillance,
and site evacuation plans. Written program can be same program used for compliance with
emergency response standard.
Training
Have all on-site personnel been trained in hazardous waste operations before participating
in any activity that could expose them to hazardous substances, safety, or health hazards?
Review training records. Training can be accomplished through compliance with Hazard
Communication standard.
Medical Surveillance
12
Has employer developed and implemented a medical surveillance program for employees
exposed to health hazards or hazardous substances, such as wastewater treatment operators?
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Purpose
Inform employees about chemicals to which they may be exposed. Chemicals of concern
include formaldehyde, ammonia, acid mist, hydrochloric and sulfuric acid, amines (dry film)
solvents, metals and nuisance dust. Facility should conduct monitoring and inform employees
of chemicals for which they have knowledge of risk or upon employee complaint.
Applicability
COMPLIANCE CHECKLIST:
Notification/Recordkeeping
Has facility notified employees about the availability of exposure records on an annual basis
(some employers post exposure records when OSHA 200 Logs are required to be
posted February 30th for 30 days)
13
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Prevent injury to workers who must enter a confined space that contains or has the potential
to contain a hazardous atmosphere or to engulf an entrant.
Applicability
Standard only applies to PWB facilities that have vessels over four feet in depth (including
sumps) that contain or have potential to pose a safety or health hazard. Internal space must
be big enough to fit a persons body (e.g., chemical and pollution control tanks, boilers).
If qualified vessels are present at facility and persons are authorized to enter such spaces,
facility must prepare a written program governing entry, employee training, air testing, and
rescue response. If facility does not allow entry, requirements are not triggered.
COMPLIANCE CHECKLIST:
Written Plan
Does facility have written program governing entry into confined spaces (i.e., list each
confined space, where it is, the hazards it presents, how authorized employees will enter
space and how air will be monitored)?
Training
Has employer trained employees that are authorized to enter confined spaces on hazards,
procedures, and skills necessary to perform job safely? Training must occur before employees
are first assigned duty, when changes are made in procedure, and when changes occur in
confined space. Proficiency must be established at least annually. Check training records.
Recordkeeping
14
Are all confined spaces labeled? If permit is required for entrance, that must be noted.
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Purpose
Standard applies to all PWB facilities. Employers are required to develop a written
emergency response plan that addresses such items as evacuation routes, personnel roles,
site security and control in the case of perils of weather, tornado, flooding, blizzard, fire,
bomb threats, earthquakes, or fires.
COMPLIANCE CHECKLIST:
Written Plan
Does facility have written program that addresses emergency response (i.e., written
emergency evacuation plan)?
Does program address fire prevention (i.e., list of major fire hazards and types of
fire protection)?
Have all employees been trained in what they must do in the case of emergency?
For example, do employees have knowledge of evacuation plan (e.g., exits)?
Testing/Drills
Does facility test emergency alarm systems on a monthly basis? Check records.
15
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Step #2
Regular facility inspections are an integral part of an effective safety and health program.
Unannounced formal team inspections should occur once a month. These formal inspections
should be augmented by daily inspections by production personnel. The following audit
checklist is designed to help evaluate a facilitys compliance with more general OSHA
requirements.
Passageways and Exits
Are all floors clean, dry, and stable (i.e., free of water, oil, grease, tools, or other
materials which could cause slipping, tripping, or falling)? If floors are wet, are
warning signs in place?
Are all stairs clear, unobstructed and with proper handrails
Comments:
Chemical/Flammable Liquid Storage
Are proper storage practices being followed (i.e., incompatible chemicals stored
separately)?
Are flammable liquids properly stored and/or handled in listed UL or FM safety cans,
original containers, or flammable liquid storage cabinet?
Are containers with self-closing lids provided for soiled or oily rags?
Comments:
Electrical Equipment
Are all electrical panels clear and easily accessible and all circuit breakers properly
labeled (i.e., function/use clearly indicated)?
Are all extension cords and power cords properly used (no overloading of circuits
or plug extenders, extension cords used on temporary basis only)?
Comments:
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Production Areas
Are all tanks, pipes, containers, and drums properly labeled according to hazcom
requirements and MSDSs available in production areas (if applicable)?
Is PPE being worn (e.g., safety glasses in drilling, routing and all wet process areas,
hearing protection in punch press, drilling, and routing areas if necessary) and appears
to be in good condition?
Are all machine guards in place? Employers must guard all machines, parts of machines, or
component part of machines which create hazardous revolving, reciprocating, running,
shearing, punching, pressing, squeezing, drawing, cutting, rolling, mixing or similar action.
Are eye wash units/ emergency showers in an accessible, highly visible location that
requires no more than 10 seconds to reach. Units/showers should be tested weekly to
verify proper operation (i.e., water flows freely for 2 minutes).
Does it appear that there is adequate ventilation (i.e., no noticeable odor, visible emissions)?
Comments:
Fire Control
Are all fire extinguishers identified, readily accessible, and in fully charged condition
(i.e., Inspection tags on fire extinguishers indicates service in past 12 months; weight
or gauge indicates charged)?
Are all sprinkler heads unpainted and unobstructed (i.e., no storage within 18
of sprinkler heads)?
Comments:
General Housekeeping
Comments:
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